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Privacy policy

This is the English version of our privacy policy. The German version (Datenschutzerklärung) is authoritative if the two differ.

1. Controller

The controller for data processing on this website and in Pukkino One, except where we act on behalf of a camp (see section 9.2), is:

Philipp Krupka
Pukkino AI Consulting
Königsberger Straße 7c
21465 Reinbek, Germany
Email: hello@pukkino.com

Further details are in our legal notice (Impressum).

2. Overview

This privacy policy explains which personal data we process when you

  • visit the website pukkino.com,
  • contact us by email or through the booking page,
  • use Pukkino One, meaning the demo at one.pukkino.com or the software as used by a camp, including access to Gmail through Google.

We process personal data in accordance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and the German Telecommunications Digital Services Data Protection Act (TDDDG).

3. Visiting this website and hosting

This website runs on a server we operate at Hetzner Online GmbH in Falkenstein, Germany. The web server Caddy delivers the pages directly from that server, without a content delivery network or any other intermediary. The domain pukkino.com is registered with Porkbun, which also manages the domain's DNS records. Porkbun does not serve the website.

On every request, the web server technically has to process the data your browser sends:

  • IP address
  • date and time of the request
  • the page requested
  • browser type and version
  • operating system

This processing is necessary to deliver the website and to keep it running securely and reliably. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is the secure and stable operation of the website.

In normal operation the web server does not write access logs. The data listed above is processed to deliver the page, but not stored in a log file. This also applies to analytics.pukkino.com. Messages about the operation of the server, such as errors, are recorded separately by the operating system and used only for troubleshooting. In individual cases they can contain IP addresses, for example when a connection fails.

4. Analytics with Umami

To understand which content is used, we use Umami, open source software that we run ourselves (analytics.pukkino.com) on the same server in Falkenstein as this website. The statistics are stored in a PostgreSQL database on that server. They are not shared with third parties.

Umami records the page visited, the referring website, browser, operating system, device type, screen size, language setting and an approximate location (country, region, city) derived from the IP address. According to the software's documentation the IP address itself is not stored. It is only used to derive the location and to form an anonymous session identifier. Umami sets no cookies and stores nothing in your browser. We only look at the data in aggregated form. If your browser sends a Do Not Track signal, Umami records nothing.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is understanding how our website is used, with as little data as possible, and improving it. You can object by enabling Do Not Track, blocking the script from analytics.pukkino.com, or sending us an email.

The statistics are kept for 12 months and then deleted. Automatic deletion after that period is not set up yet. Until it is, the data stays until it is deleted by hand.

5. Contact by email

If you email us, we process your email address, your name and the content of your message to answer your request and any further questions. The legal basis is Art. 6(1)(b) GDPR if your request relates to a contract, otherwise Art. 6(1)(f) GDPR. We do not share this data without your consent and delete it once it is no longer needed and no statutory retention period applies.

Our mailboxes (hello@pukkino.com and phil@pukkino.com) are hosted by Zoho (Zoho Mail). Your message is stored and processed on Zoho's servers so that we can receive and answer it.

6. Booking a call with Cal.com

For booking calls we link to Cal.com (Cal.com, Inc.). You are only taken to Cal.com when you follow the link. We use the details you enter there, such as your name, email address, the chosen time and an optional message, to prepare and hold the call. The legal basis is Art. 6(1)(b) GDPR. Details on processing by Cal.com: https://cal.com/privacy.

7. YouTube videos

The projects page shows videos from YouTube, provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. The videos are only loaded when you click "Play video". Until then, no data is sent to YouTube or Google.

After the click, the video is loaded from youtube-nocookie.com, and Google receives your IP address and information about the request, among other things. The legal basis is your consent given by clicking (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). More information is in Google's privacy policy: https://policies.google.com/privacy.

8. Fonts and browser storage

The fonts on this website are served from our own server. No connection is made to Google Fonts or any other font provider.

If you switch the language with the DE/EN button, or switch between the light and dark design with the sun and moon button, the website stores that choice in your browser's local storage (entries "pukkino-lang" and "pukkino-theme"). The home page then opens in that language next time and the site appears in the design you chose. The entries stay in your browser and are not sent to us. As long as you do not change either yourself, nothing is stored, and the site appears in the light design. The legal basis is Section 25(2) no. 2 TDDDG, because you explicitly chose the function. You can delete the entries in your browser settings at any time.

9. Pukkino One and Gmail

Pukkino One is software we develop for running surf camps. Camps use it under an individual agreement with us. This section describes which data Pukkino One processes, in particular when accessing Gmail through Google APIs.

9.1 The demo at one.pukkino.com and external content

The public demo runs entirely in your browser and only uses sample data that ships with it. It is not connected to customer data, databases or Google accounts. Settings and changes you make in the demo, such as the selected view, the theme or templates, are only stored locally in your browser. They are not sent to us.

When you open the demo, our server processes the data listed in section 3 in its log files. In addition, the application connects to the following services, in the demo as well as when used by a camp, and they receive your IP address:

  • Open-Meteo (open-meteo.com) for current wave and weather data at the surf spot, once the application is open,
  • YouTube (Google Ireland Limited) for thumbnails of surf tutorials in the guest view.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is displaying the application and making it work.

The demo serves its fonts from our own server and makes no connection to Google Fonts. The version of the application that camps currently use still loads its typeface from Google Fonts (Google Ireland Limited), which then receives your IP address. We are changing this so that this version also serves its fonts from our own server.

9.2 Pukkino One in use at a camp

When a camp uses Pukkino One in its operations, the camp decides which data about its guests is processed. The camp is the controller for this data under the GDPR. We process it as a processor under Art. 28 GDPR, only on behalf of and as instructed by the camp. This also applies to the team's user accounts (name, email address, role).

Guests of a camp should contact the camp first with questions about their data. We forward requests that reach us to the camp.

9.3 Access to Gmail through Google OAuth

The email module of Pukkino One needs access to the camp's Gmail mailbox. The camp grants this access itself: it signs in with its Google account on Google's consent page (OAuth) and agrees to the requested permissions. The connection is set up in n8n, the automation platform we run ourselves. We never receive a password. The access authorisation is stored encrypted in n8n, the automation platform we run ourselves, and is only used for the functions below.

Reading

n8n checks the mailbox at short intervals for new messages that are meant to be processed. Depending on the setup, these are all unread messages in the inbox or only messages carrying a label chosen by the camp. From these messages we process:

  • message ID and conversation (thread) ID
  • sender name and email address
  • subject
  • message body as plain text and as HTML

Sending

Replies are sent from the camp's Gmail account, and only after an authorised member of the camp's team has reviewed and approved the draft in Pukkino One. Pukkino One does not send replies without this approval.

Labels

Depending on the setup, Pukkino One adds a label to processed messages so the status is visible in the mailbox.

What Pukkino One does not do

Pukkino One does not delete messages from the mailbox, does not change message content, does not access contacts or calendars, and does not use the access for advertising or any purpose other than those described here.

Purpose and legal basis

We process this data to capture guest enquiries, recognise booking requests in them, check availability and give the camp's team a draft reply to review. We do this on behalf of the camp (Art. 28 GDPR). On the camp's side, the legal basis is usually handling enquiries and carrying out bookings (Art. 6(1)(b) GDPR).

9.4 Attachments

Attachments are not stored in the Pukkino One database and are not sent to AI services. At most, Pukkino One records file name, file type and file size so the team can see that a message has attachments. The files themselves stay in the camp's Gmail mailbox. Where n8n briefly loads attachments while fetching a message, they are only part of the execution logs (see section 9.9).

9.5 Storage in Pukkino One

For each captured message, Pukkino One stores the following in a Supabase database hosted in the EU (Ireland):

  • sender, subject, message body as text and HTML, and the Gmail message and thread IDs
  • the detected category of the message
  • details recognised in it, such as travel dates, number of guests, room and package preferences, and flight details for transfers
  • the availability at the time it was checked
  • the draft reply, the reply actually sent, who approved it, internal notes and timestamps

This data can only be accessed by the camp's administrators after signing in, and by us for operation, maintenance and troubleshooting as the camp's processor, subject to the restrictions in section 9.11. For troubleshooting, the system also logs the individual processing steps. These logs are likewise only visible to administrators.

9.6 AI processing

Anthropic (Claude). To decide whether a message is a guest enquiry, we send the sender, subject and the start of the message body to Anthropic's API. For the draft reply, we send the content of the enquiry together with the stored camp information, rates and the result of the availability check.

OpenAI. To find relevant camp information, we create a numerical representation (embedding) of the subject and message body. This content is sent to OpenAI's API for that purpose. The embedding is only used for this search and is not stored.

Under both providers' commercial terms, data sent through their APIs is not used to train their models. We do not train any AI models on this data ourselves.

The AI never decides on its own to send anything. Every draft is reviewed by a person. Drafts that state rates, dates, packages or availability not backed by the stored data are discarded automatically.

9.7 Google Sheets

Camps often keep occupancy and bookings in Google Sheets. Pukkino One reads these sheets through a technical service account to check availability and show guests and bookings. When the team confirms a booking, a transfer or a payment, Pukkino One writes the related details into these sheets, such as name, email address, travel dates, room, package and flight details. The service account can only access sheets the camp has shared with it.

9.8 Recipients and processors

For Pukkino One we use the following service providers:

  • Google Ireland Limited, Ireland: Gmail and Google Sheets. These are the camp's own accounts.
  • Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany: server in Falkenstein (Germany) on which we run n8n, the demo, Umami and this website.
  • Supabase, Inc., USA: database, authentication and server functions, hosted in the EU (Ireland).
  • Anthropic PBC, USA: message classification and draft replies.
  • OpenAI, USA: embeddings for searching camp information.

We do not sell data and do not use it for advertising.

9.9 Retention and backups

Messages, drafts, extracted details and the related processing logs in Pukkino One are kept for 12 months after receipt and then deleted. Automatic deletion after that period is not set up yet. Until it is, the data stays until it is deleted on request or by hand.

n8n keeps execution logs that can contain the content of processed messages. They are deleted after 14 days by n8n's automatic clean up.

On our server in Falkenstein, local backups of the n8n databases and the server configuration are made daily and kept for 7 days. Execution logs deleted from n8n can therefore remain in these backups for up to 7 more days. The Pukkino One database at Supabase is not part of these backups. Backups that Supabase itself may keep follow its own retention periods.

When our work with a camp ends, we delete the camp's data in Pukkino One or return it to the camp, unless a statutory retention period applies.

9.10 Revoking access and deleting data

The camp can revoke Pukkino One's access to its Google account at any time, either in the Google account settings at https://myaccount.google.com/connections or by asking us to remove the connection. After that, Pukkino One can no longer read or send messages.

Data already stored in Pukkino One is not affected by revoking access. The camp can ask for it to be deleted at any time by emailing hello@pukkino.com. Guests of a camp can ask the camp to delete their data, and we carry out such deletions on the camp's behalf.

9.11 Google API Services User Data Policy

Pukkino One's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular:

  • We only use Gmail data to provide and improve the user-facing features of Pukkino One for the camp.
  • We only transfer Gmail data to the service providers listed in section 9.8 where this is necessary for those features, or where required by law.
  • We do not use Gmail data for advertising, do not sell it and do not pass it on to data brokers.
  • We do not use Gmail data to develop, improve or train generalised AI or machine learning models.
  • People at Pukkino only read Gmail data if the camp has agreed to it for specific messages, for example in a support request, if it is necessary for security purposes such as investigating abuse, or if required by law.

10. Transfers outside the EU

Some of the providers named above are based in the USA or may process data there, in particular Anthropic, OpenAI, Supabase, Cal.com and, when you play videos, Google. A transfer there is only permitted with suitable safeguards (Art. 44 et seq. GDPR), such as Standard Contractual Clauses or a certification under the EU-US Data Privacy Framework.

11. Your rights

You have the right to

  • access the data we hold about you (Art. 15 GDPR),
  • have incorrect data corrected (Art. 16 GDPR),
  • have your data deleted (Art. 17 GDPR),
  • restrict processing (Art. 18 GDPR),
  • data portability (Art. 20 GDPR),
  • object to processing (Art. 21 GDPR),
  • withdraw consent with effect for the future (Art. 7(3) GDPR),
  • lodge a complaint with a supervisory authority (Art. 77 GDPR).

Right to object: where we process data based on Art. 6(1)(f) GDPR, you can object at any time on grounds relating to your particular situation.

Our supervisory authority is the Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD), but you can contact any other supervisory authority. For any request, an email to hello@pukkino.com is enough.

12. Changes

We update this privacy policy when our services or the law change. The version published here is the one that applies.

Last updated: September 2026